IR 05000289/1973010
| ML19256D523 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/11/1973 |
| From: | Glasscock R, Spessard R, Tillou J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D520 | List: |
| References | |
| 50-289-73-10, NUDOCS 7910180835 | |
| Download: ML19256D523 (11) | |
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U. S. AT0>11C E0ERGY C0!O!ISSION
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DIRECTORATE OF REGULATORY OPERATIO:*S
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REGION I
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- R0 Inspection Report No.:
50-289/73-10 50-289 Docket No.:
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Metropolitan Edis9n Company Wem Nm * CPPR-40 Licensec:
Three Mile Island
Priority:
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Category:
B1
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Middletown, Pennsylvania l
Locction:..
I #8
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' Type of Inspection: Routine, Announced
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Dates of Inspection: August 14 and 15, 1973 Dates of Previous Inspection:
August 14 and 15, 1973 Reporting Inspector:
.w M
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R.B.Glassc[ck,ReactorInsp6ctor DATE
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Accompanying Inspectors:
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R.L.Spessard/ReactorInspector DATE
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DATE
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Other Accompanying Personnel:
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DATE O \\ [/ 7 e r,-c, fM~7%
Reviewed By:
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J. H. Tillou, Senior Reactor Inspector DATE
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E. J Brunner, Chief Facility Test and Startup Branch DAT E p41+ao W7gg i gon 5
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SUMMARY OF FINDI"CS Enforcement Action None Licensee Action on Previously Identified Enforcement Items Not applicable
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l Design Changes
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Not applicabic
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Unusual Occurrences
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Not applicable Other Significant Findings
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A.
Current Findings 1.
Pro' gram Evaluation A review of the Three Mile Island Quality Assurance Progran for Start-up and Test Activities indicates the program is not consistent with Appendix B to 10 CFR 50.
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Unresolved Items Criterion II Paragraph 2.a.
Criterion X Paragraph 2.b.
Criterion XI Paragraph 2.c.
Criterion XV Paragraph 2.d.
Sc'iduled Audit No. 11 Paragraph 5 1451 112
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B.
Status of Previously Reported Unresolved Items 1.
Audit schedule encompassing all aspects of the QA Program for Startup and Test Activities (20 Inspection Report No. 50-239/73-06)-Item is considered resolved based on further review of the Licensee's program (Paragraph 4).
Managenent Interview
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An exit interview was held at the cone?,sion of che inspection on August 15, 1973.
Persennel Attending
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I GPUSC
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j G. Miller, Test Superintendent
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R. Toole, Assistant Test Superintendent *
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i J. Renshaw, Quality Assurance Engineer j
J. Wright, Quality Assurance Manager M. Stromberg, Site Auditor
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l T. Sturgeon, Quality Assurance Engineer U
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R. McLaughlin, Manager, Operational Quality Assurance W. Potts, Quality Assurance Engineer i
J. lierbein, Assistant Plant Superintendent
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UE & C E. McDevitt, Lead Startup Engineer USAEC-RO:I R. Spessard, Reactor Inspector R. Glasscock, Reactor Inspector
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The following items were discussed:
A.
Scone of the Insnectic,g The inspector stated this inspection consisted of an evaluation of the Three Mile Island Quality Assurance Program for Startup and Test Activities which included both the Plan, the Test Manual, and referenced Test Instructions.
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B.
Test Ins truction Number 9 The inspector stated that Test Instruction Number 9 needed to reflect the current practice of the Shif t Test Engineer review-ing system drawing revisions immediately prior to performance j
of tests.
(Details, Paragraph 3)
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The Licensee concurred.
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Criterion II, Anpendix B. 10 CFR 50 The inspector stated Test Instruction Number 19 needed to be j
revised to require the application of the Design 'and Construction Quality Assurance Program to all equipment that becomes a per-
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manent part of the facility.
(Details, Paragraph 2.a. )
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The Licensee agreed to the above.
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D.
Criterien X, Appendix B, 10 CFR 50
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The inspector stated Section X of the Quality Assurance Plan needed to be revised to include the audit of Preoperational llh
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and Startup Tests by the TMI Site QA Organization, and that the audits should be scheduled commensurate with the test schedule.
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(Details, Paragraph 2.b.)
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I The Licensee agreed to revise the Plan to include the above.
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E.
Criterion XI, Anpendix B, 10 CFR 50 i
The inspector stated test devices needed to be defined and controlled to assure they would not affect the validity of test results.
(Details, Paragraph 2.c. )
The Licensee agreed to revise the appropriate instructions to define the controls.
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Criterion XV, Annendix B, 10 CFR 50
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The inspector stated the program needed to be revised to pro-vide for appropriate design agency review of problem reports if the final design of the plant is affected.
(Details, Paragraph 2.d.)
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The Licensee agreed to revise the appropriate instructions to comply.
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Audit Program Covering Startuo and Test Activities The inspector stated that, based on a review of the Site QA Organization's formal audit program covering the Construction
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and Preoperational Test Phases of the TMI Test Program and l
the commitment received from Licensee Representatives relative
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to the identification of preoperational tests to be audited
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by the Site QA Organization, he had no further questions on j
this matter at this time and that it was considered resolved. *
j The inspector further stated that it was understood, based on provisions contained in this audit program and discussions
with Licensee Representatives, that a similac schedule and chart
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covering the Initial Startup Phase of the TMI Test Program would be prepared at the earliest practicable time, consistent with the
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schedule for accomplishing this phase of the test program.
I Licensee Representatives acknowledged this understanding.
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Scheduled Audit No. 11
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The inspector stated that a review of this audit, which was
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performed on August 9,1973 by a member of the Site QA Organ-i ization, indicated the audit was not comprehensive pursuant
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to Criterion XVIII, Appendix B, 10 CFR 50 and it was real-
ized that the audit results had not had the final management evaluation when reviewed by the inspector.
The inspector stated
that this matter was considered to be an unresolved item, and that it was his understanding that the audit would be reper-formed.
Licensee Representatives acknowledged this understanding (Paragraph 5).
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gperations Quality Assurance Program i
The inspector stated it was his understanding that the Opera-tions Quality Assurance Program as related to test and startup activities was not complete and that Met Ed was relying on GPUSC to perform all quality assurance functions until the appropriate sections of the Operations Quality Assurance Program were com-pleted.
- RO Inspection Report No. 50-289/73-06, Management Interview Item G.3 and Paragraph 4.d.
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The Licensee concurred and stated that the '4et Ed Quality
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Assurance Program is for Operations and will interface with the Test and Startup Quality Assurance Program, but will not duplicate it.
(Paragraph 7)
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DETAILS
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Persons Contacted J. Herbein, Met Ed, Assistant Plant Superintendent J. Fritzen, Met Ed, Test Auditor R. McLaughlin, Met Ed, Manager, Operational Quality Assurance W. Potts, Met Ed, Quality Assurance Engineer
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J. Barton, GPUSC, Startup and Test Manager
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G. Miller, GPUSC, Test Superintendent J. Wright, GPUSC, TMI Quality Assurance Manager I
M. Stromberg, CPUSC, Site Auditor
J. Renshaw, CPUSC, Quality Assurance Engineer
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T. Sturgeon, GPUSC, Quality Assurance Enginee,r 2.
Quali ty Assurance Program for Startuo and Test Activities
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The Quality Assurance Program for Test and Startup, which included
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the Quality Assurance Plan for Startup and Test, and Instructions referenced by the Quality Assurance Plan, was evaluated for com-
pliance with Appendix B.
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The inspector observed that the program deficiencies identified
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during previous inspections * had been corrected. Additionally
.j the inspector observed that Test Instructions Nos. 5, 8, 9, and 13 had been approved and issued on the dates previously committed to i
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j The deficiencies identified during the program evaluation, with
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the Licensee co=mitments, are listed below.
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Criterion II, Appendix B, 10 CFR 50 Contrary to the requirements of Criterion II, Test Instruction Number 19 fails to make a distinction as to the controls to be applied to all test equipment.
A Licensee Representative agreed to change Test Instruction Number 19 to require the application of the Design and Construction Quality Assurance Program to all tesc equipment that becomes a permanent part of the f acility.
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'R0 Inspection Report No. 50-289/72-17, Paragraph 2
- RO Inspection Report No. 50-289/73-06, Management Interview Item G.5
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b.
Criterion X, Appendix B, 10 CFR 50 Contrary to the requirements of Criterion X, the program does not provide for independent verification of test performance
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for preoperational and startup tests.
Licensee Represent-
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performance in accordance with the requirements of Section
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XVIII of the Test and Startup QA Plan.
They also agreed
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to review the test schedule and establish the audit schedule
commensurate with the test schedule, c.
Criterion XI, Appendix B, 10 CFR 50
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Contrary to the requirements of Criterion XI, Test Instruction l
Number 19 allows the use of Test Devices (which are not defined)
with minimum controls over their design and fabrication.
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licensee Representative agreed to make the following changes l
to Test Instruction Number 19 to prbvide the necessary control:
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Paragraph 2.0, add, " Test Devices are one of a kind items
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specifically to provide some function to support performance of a particular test procedure."
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Paragraph 3.2.2.2, add, "The detail sketch above with its
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designated final construction checks are approved by the
. cognizant test engineer as to the acceptability of its use
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in testing in accordance with a particular test procedure, thus assuring that the use of the test device as specified
in its associated procedure will not affect test results."
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d.
Criterion XV, Apoendix B, 10 CFR 50 Contrary to the requirements of Criterion XV, the Test Startup Quality Assurance Plan does not establish measures to prevent inadvertent use of items which do not conform to design requirements.
For example, the Test and Startup Quality Assurance Plan or the referenced Test Instruction Number 7 do not include provisions for the application of design _ controls, as defined by Criterion III of Appendix B, for problems related to design.
A Licensee 2epresentative agreed to revise the test instruct-ion to require appropriate design agency review of problem reports if the final design of the plant is affected.
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3.
Test Instruction No. 9 Conduct of Test A review of this test inatruction disclosed that the current practice of the Shif t T(
Engineer's review of system drawing revisions immediately prior to starting a test was not included in this instruction.
A licensee representative stated this matter would be added as a requirement in paragraph 3.3.1.7 of instruction.
4.
Audit Program covering Startup and Test Activities During a previous RO inspection, * it was determined that the site
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QA organization had not completely finalized a detailed audit schedule encompassing all aspects of the QA Program for Startup
and Test Activities and a licensee commitacnt to complete this
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schedule at an early date was obtained.
During this R0 inspection,
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the inspector reviewed the formal audit prograr., which had been
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prepared by the T4I Site QA Organization'on July 6,1973 and
approved for performance by the Manager of Quality Assurance on July 9,1973, and discussed the program requirements with cognizant
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site QA personnel.
This program covers the Construction Test and
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Preoperational Test Phases of the TMI Test Program and provides L)
schedules and charts which delineate the areas to be audited, the scheduled dates.for these audits, the status of these audits, and
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i the requirements for these audits.
Additionally, the program est-ablishes the requirement to provide a similar schedule and chart covering the Initial Startup Phase of the TMI Test Program (starts with initial fuel loading and ends upon completion of the power escalation test program).
During dicussions relative to program requiremenr3, the inspector was informed that the scheduling of safety related preoperational tests for audit by the site QA organization was determined by reviewing approved Test Plans.
The inspector was also informed that a list of the preoperational tests to be witnessed in accordance with the audit program would be developed. With respect-to the development of a schedule and chart covering the Initial Startup Phase of the TMI Test Program, the inspector was informed that this would be accomplished at the earliest practicable time, consistent with the schedule for accom-plishing this phase of the program.
Site QA personnel indicated the schedule for the Initial Startup Phase had not been finalized.
The inspector determined that this formal audit program, as des-cribed above, would cover all aspects of the QA Program for Startup and Test Activities, and he informed the Site QA personnel that he had no further questions on this matter at this time and that it was considered resolved.
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- R0 Inspection Report Na. 50-289/73-06, Management Interview G.3 and Paragraph 4.d.
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5.
Scheduled Audit No. 11
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A review of the audit plan and results of this scheduled audit was made by the inspector.
The audit which was performed on
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Augus t 9,1973 did not appear to be a comprehensive audit i
pursuant to Criterion XVIII, Appendix B,10 CFR 50 in that both
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the plan and results were not detailed.
A Licensee Represent-utive stated the audit was performed by a new can and that it had not had the final management review.
He further stated that even though this audit was considered to be in the draft stage at this time it would be redone.
The inspector stated that i
this matter was considered to be an unresolved item and would be reviewed during a subsequent RO inspection.
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Test Auditor's Activities l
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An insp< : tion was made, at the Reading,.Pa. of fices of Met Ed, to evaluate implementation of the Test Auditor's functions as defined by Sec2 ion XVIII of the Quality Assurance Plan.
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deficiencies were identified.
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Apolication of the Operating Ouality Assurance Plan Referenced bv the Test and Startup Quality Assurance Plan.
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A review was made to determine the status of the Operations
Quality Assurance Program.
A Licensee Representative stated
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the Operations Quality Assurance Program was not complete and was
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not being applied to the Test and Startup activities.
He further stated that the Design and Construction Quality Assurance Program, i
directed by GPUSC, would continue to be applied, even in those sections where there is an option to use either plan, until the appropriate sections of the Operations Quality Assurance Pro-gram are completed (this includes implementation procedures).
It was further indicated by the Licensee Representative that the Operations Quality Assurance Program as related to the Test and Star tup activities would be complete in about four weeks.
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For concurrence.
For action.
t MEMO ROUTE SLIP Form AFC-93 (Rev. May 14,1947) AECM 0240 Note and retura.
For signature.
For information.
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TO (Name and unst)
IMTIALS REMARKS ROINSPECTIONREPORTNO.50-289h-1 l
RO Chie f, Field Suppo -t and Enf,, Br., HQ RO:HQ (5)
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METROPOLITAN EDISON CO RO Files oATE I
[ Central Mail and File i
Regulatcry Standards f3)
TO (Narne anwwnet)
INTIALS REM AAKS Directorate of Licens mng (13)
The attached report is being forwarded for informatio.n.
RO Directors (4)
Distribution to PDR, Local PDR, NSIC, DTIE and state oAn
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represerttatives will be mcde af ter proprietary review l
TO (Name and unit)
IM TIALS rem UtKS is complated by the licensee.
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FRCM (Name and unst)
REMARKS E. Morris Howard RO:Ia rs + >
PHONEf6 DATE
278 9/11/73 h
CPo: 1511 0 - **5 ed '
45E OTHEA 54CE FOR ADQtTION AL REMAftKS
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